Chamberlain Group, Inc. v. Skylnk Tech., Inc.
381 F.3d 1178 (Fed. Cir. 2004)
Chamberlain made garage door
openers. Each opener used a unique 'code' between the transmitter and the
opener for security.
Skylink made replacement
garage door opener transmitters. They could be programmed to emit any
code, so they would work with any garage door opener.
Chamberlain sued for copyright
Chamberlain argued that
Skylink's product was a device intended to circumvent a technological measure that controls access
to Chamberlain's copyrighted 'codes'. Therefore it was a violation of
the Digital Millennium Copyright Act (DMCA) (17 U.S.C. §1201(a)(2)), which makes it illegal to manufacture or
offer a device to aid circumvention.
The Trial Court found for
Skylink. Chamberlain appealed.
The Trial Court found that
since there were no conditions on the sale of their openers, the customer
had an implied authorization to
access the 'code'.
The Appellate Court affirmed.
The Appellate Court found
that circumvention is defined by §1201(a)(3)(A)
as "activity undertaken without the authority of the copyright
The Court found that since
customers had been implicitly authorized to use the code to open their
doors, their activity was not circumvention, and any device Skylink made to help them couldn't be considered
a device to aid circumvention.
transmitter enabled only legitimate uses of copyrighted code. Therefore
it was not covered by §1201(a)(2).
Basically, the Court was
saying that the DMCA only
prohibits forms of circumvention that constitute a threat to other
rights under copyright law (like 17 U.S.C. §106). Since Chamberlain didn't have the right
to restrict people from using the codes to open their garage doors, DMCA did not give them the right to prevent
people from circumventing the copy protection blocking access to the
In more technical language,
this case said that in order to constitute a violation of §1201(a)(2) a plaintiff must establish that they had
ownership of a copyrighted work effectively controlled by a technological
measure which has been circumvented so that third parties can now access
it without authorization in a way that infringes or facilitates
infringement of rights protected by 17 U.S.C. §106, because of a product that the defendant
Designed or produced
primarily for circumvention,
Made available despite only
limited commercial significance other than to circumvent, or
Marketed for use in
circumvention of the controlling technological measure.